A.Sujitha vs J.Radhakrishnan on 13 July, 2026

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    Madras High Court

    A.Sujitha vs J.Radhakrishnan on 13 July, 2026

    Author: Anita Sumanth

    Bench: Anita Sumanth

        2026:MHC:2753
    
    
    
                                                                         LPA No. 3 of 2026
    
    
                                      IN THE HIGH COURT OF JUDICATURE AT MADRAS
                                                   DATED: 13.07.2026
                                                          CORAM
                                        THE HON'BLE DR.JUSTICE ANITA SUMANTH
                                                           AND
                                        THE HON'BLE MR.JUSTICE SUNDER MOHAN
                                                   LPA No. 3 of 2026
                                                          and
                                                 CMP NO. 10754 OF 2026
    
                          A.Sujitha
                          E-105, SRM Green Pearl Apartment,
                          Periyar Street,
                          Potheri,
                          Previously Kancheepuram
                          Now Chengalpattu Dt., Pin – 603203
                                                                                ..Appellant(s)
                                                           Vs
                          1. J.Radhakrishnan
                             Chairman and Managing Director,
                             TANGENDCO,
                             New NO.144, Anna Salai
                             N.P.K.R.R.Maligai
                             Chennai-600002.
    
                          2. M.Ambiga
                             Chief Engineer (Personnel)
                             TANGENDCO
                             New No.144, Anna Salai
                             Chennai-600002
    
                                                                               ..Respondent(s)
    
    
    
    
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                                                                                       LPA No. 3 of 2026
    
    
    
    
                                      Appeal filed under Clause 15 of Letters Patent to set aside the order
    
                         dated 28.11.2025 in Contempt Petition No.3033/2025.
    
                                         For Appellant(s):        Dr.A.E.Chelliah, Senior Counsel
                                                                  for Mr.V.J.Arulraj
    
                                         For Respondent(s):       Mr.Anand Gopalan
                                                                  for M/s.Advit Law Chambers
                                                                  For R1 & R2
    
    
                                                              JUDGMENT
    

    (Delivered by Dr.Anita Sumanth J.)
    This Letter Patent Appeal under Section 19 of the Contempt of

    Courts Act 1971 (‘Act’), challenges an order dated 21.11.2025 dismissing

    SPONSORED

    Contempt Petition Nos.2599 & 3033 of 2025. Those petitions arose out of

    orders made on 09.03.2021 and 29.09.2023 in W.P.No.5691 of 2021 and

    W.P.No.5843 of 2020, respectively. W.P.No.5843 of 2020 was filed with

    the following prayer:-

    Writ Petition filed under Article 226 of the
    Constitution of India praying for issuance of a
    writ of declaration, declaring the action of the
    second respondent in not considering the
    petitioner for the appointment to the post of
    Assistant Engineer (Electrical) under the member
    of family whose lands are acquired by the
    Government priority quota as null and void and
    thereby direct the second respondent herein to

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    select and appoint the petitioner with Registration
    No.201601285 to the post of Assistant Engineer
    (Electrical) pursuant to the notification
    No.01/2018 dated 14.02.2018 in the existing
    vacancy with all monetary and service benefits.

    2. The writ petition came to be allowed on 29.09.2023, this Court

    issuing a direction for appointment of the Appellant within a period of 8

    weeks from date of receipt of a copy of the order.

    3. As against the aforesaid order, W.A.No. 1401 of 2024 has been

    filed by the Respondents. When the writ appeal had come up for

    admission, it is the say of the appellant represented by Mr.V.J.Arulraj for

    whom Dr.A.E.Chelliah, learned senior counsel appears, that it had merely

    been adjourned whereas it is the say of Mr.Anand Gopalan, who appears

    for the respondents that the appellant had undertaken before the Division

    Bench not to press the contempt petition till disposal of the writ appeal.

    4. Ultimately, the contempt petition had come to be dismissed,

    learned Judge concluding that it was not maintainable as it had been

    instituted beyond the period of limitation prescribed under the Act.

    5. Dr.Chelliah argues that the period of limitation provided under

    the Act is not rigid, and that there is no fetter on the Courts in exercising

    the power of contempt. He urges that the Court must accommodate the

    realities of the present situation where, the appellant is unemployed
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    despite having obtained a positive order from the writ court for

    employment. She should hence not be non-suited on mere technicalities.

    6. For this purpose, appellant would rely on the judgment of the

    Supreme Court in Rupa Ashok Hurra Vs. Ashok Hurra and another1 and

    judgment of this Court in Murugesan Gounder and other v Brindhavathi

    ammal and others2 confirmed in Murugesa Gounder v Brindhavathi

    ammal and ors3.

    7. Per contra, learned counsel for respondent would submit that the

    period of limitation provided for under Section 20 does not admit of any

    flexibility or laxity. That apart, the present appeal is not even

    maintainable, he would argue, relying on Section 19 of the Act, as per

    which, an appeal would lie only as against an order or decision punishing

    an individual for contempt. In the present case, the impugned order does

    not impose any punishment.

    8. Mr.Gopalan relies on the following decisions:

    (i) T.Marappan v The Executive Engineer and Administrative
    Officer, Salem
    and another4

    (ii) Major S Veerasamy v The Management of Andhra Social
    and Cultural Association
    and another5

    1
    AIR 202 SC 1771
    2
    S.A.No.1602 of 2008 dated 17.02.2011
    3
    SLP(C) No. 21528 of 2011 on 31.03.2015
    4
    (1996) SCC OnLine Mad 339 : (1996) 2 LW 117
    5
    1996 SCC OnLine Mad 625 : (1997) 2 LW 671

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    (iii) Midnapore Peoples’ COOP. Bank Ltd and others v
    Chunilal Nanda
    and others6

    (iv)Tamilnad Mercantile Bank Shareholders Welfare
    Association v S.C..Sekar and others7

    (v) M.Devaraj and others v Noor Mohammed, Superintending
    Engineer, Thiruvannamalai Electricity Distribution Circle,
    Tangedco, Vengikkal, Thiruvannamalai.8

    (vi) Baradakanta Mishra v Justice Gatikrushna Misra, Chief
    Justice of the Orissa High Court9

    (vii) B.Surendra Reddy v K.Devarajan and others10

    (viii) S.Tirupathi Rao v M.Lingamaiah and Others11

    9. We have heard both learned counsel and had perused the

    material papers as well as case law.

    10. In W.P.No.5691 of 2021 the appellant had sought a Mandamus

    directing the respondents to consider her plea for employment. The writ

    petition was disposed on 09.03.2021, the writ court directing disposal of

    representation of the appellant in accordance with law. No order was

    passed, and instead, Notification No.1 of 2018 dated 14.02.2018 came to

    be issued calling for applications for 300 vacancies for the post of

    Assistant Engineer (Electrical). The appellant had applied but was

    unsuccessful.

    11. Notification No.2/2020 then came to be issued on 08.01.2020

    6
    (2006) 5 SCC 399 : 2006 SCC OnLine 628
    7
    (2009) 2 SCC 784 : 2008 SCC OnLine SC 1831
    8
    LPA No.2 of 2020 dt 4.3.2020
    9
    (1975) 3 SCC 535
    10
    Cont P No.743 of 2022 dated 20.06.2022
    11
    (2024) 20 SCC 188

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    inviting applications for 400 vacancies. The age limit was fixed as 32

    years which rendered the appellant ineligible to apply for the post. It is

    hence that Writ Petition No.5843 of 2020 had come to be filed by her

    seeking a declaration that she be appointed under Notification No.1/2018

    itself. The writ court allowed the writ petition on 29.9.2023 and directed

    the authorities to appoint her under the 2018 Notification within 8 weeks

    from date of receipt of that order.

    12. The writ order dated 29.09.23 had been made ready on

    08.12.2023 and the period of one year thus ended on 08.12.2024. The

    contempt petition was instituted on 12.08.2025 with a delay of more than

    8 months. One of the grounds on which the petition has come to be

    dismissed is that it is barred by limitation and the argument on behalf of

    the appellant is that period of limitation provided under the Act should

    not be construed such that it defeats substantive justice.

    13. Section 20 of the Act sets out the limitation for action for

    contempt and states that no Court shall initiate any proceedings for

    contempt, either on its own motion or otherwise, after expiry of a period

    of one year from the date on which the contempt is alleged to have been

    committed. The clear language of Section 20 leaves us in no doubt that

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    the limitation provided for is to be strictly applied.

    14. In Pallav Seth Vs. Custodian and Others12, three Hon’ble

    judges of the Supreme Court considered a situation where the Custodian

    of the Special Court for trial of offences relating to transactions in

    securities, had pursued action for contempt as against the Appellant. The

    facts in Pallav Sheth’s case was that a Decree as against that Appellant

    had been passed on 24.02.1994 and an Execution Petition had been

    moved by the Custodian in 1994 itself.

    15. The Special Court then passed an order of attachment on

    24.08.94. There was a raid conducted in November 1997 in the premises

    of the Appellant that had been publicised in the media following which

    the Special Court directed the Custodian to ascertain from the Department

    the extent of that Appellants’ assets. It was only on receiving information

    from the Income tax Department vide letter dated 5.5.98, that it came to

    be known that the appellant had perpetrated fraud on the Custodian. The

    contempt application had been filed by the Custodian within a period of

    one year from the aforesaid date.

    16. On the above facts, the Court held that the period of limitation

    under Section 20 would commence from the date on which the fraud
    12
    AIR 201 SC 2673

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    played by the party on the Court / opposite party had been discovered,

    and since that Appellant had acted fraudulently by suppressing

    information, the question of bar of limitation would not arise. The Court

    thus held that where the party had not slept over his rights, and if the

    Court were convinced that action for contempt will lie, power may be

    exercised under Article 215 of the Constitution to punish for contempt.

    17. The view taken by two Judges in Om Prakash Jaiswal v

    D.K.Mittal13, that, filing of an application for initiating contempt did not

    amount to initiation of proceedings by the Court and initiation under

    Section 20 can only be said to have occurred when the Court forms a

    prima facie opinion that contempt had been punished and thus issues

    notice, did not find favour with the Bench in Pallav Seth.

    18. The Supreme Court, in S.Tirupathi Rao v M.Lingamaiah14 has

    made reference to Pallav Seth’s15 case noting the circumstances in which

    the Court had considered the argument of bar of limitation. In Tirupathi

    Rao’s case, the legal issue crystalised for resolution was the terminus a

    quo for commencement of the point of limitation in contempt matters and

    13
    (2000) 3 SCC 171
    14
    (2024) 20 SCC 188
    15
    Foot Note Supra 12

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    the interplay between Section 20 of the Act read with Article 215 of the

    Constitution.

    19. The facts are not germane except to state that the specific

    argument dealt with by the Court was that there had been a continuing

    harm/offence for which that petitioner had sought exemption from the bar

    of limitation. The Court held that action for contempt is essentially in the

    nature of an original proceeding, citing the judgment of the Supreme

    Court in High Court of Judicature at Allahabad v Raj Kishore Yadav16.

    20. Hence, the express negative phraseology employed in Section

    20 of the Act would act as a legislative injunction placing a fetter on the

    power of the Court to initiate proceedings for contempt, where the

    petition had been presented beyond the time frame stipulated statutorily.

    21. However, an exception was made possible by the expression

    ‘date on which the contempt is alleged to be committed’ which is the

    starting point of the period of one year to be reckoned for limitation, and

    one of the ways by which this may be pressed into service by a petitioner,

    would be by invoking the principle flowing from Order VII Rule 6 of

    CPC, by showing the ground upon which the exemption is claimed.

    16

    (1997) 3 SCC 11

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    22. For instance, in a case where civil contempt is alleged by a

    party making reference to a continuing wrong and the party satisfies the

    Court of such continuing offence, then it is open to the Court to consider

    the same. The discretion as to whether this approach is to be taken or not

    would depend entirely upon the Court being satisfied that the benefit of

    the exemption, and the principle underlying Order VII Rule 6 CPC,

    should be extended in a given case.

    23. In Tirupathi Rao’s case the Bench makes it clear that the Court

    cannot grant exemption from limitation on equitable considerations or on

    the ground of hardship. Drawing inspiration from the judgment of the

    Privy Council in Maqbul Ahmad v Onkar Pratap Narain Singh 17, the

    conclusion was that contempt proceedings being original proceedings

    akin to a suit, the question of seeking condonation of delay in instituting a

    contempt petition is not available to the petitioner. The period set out

    under Section 20 of the Act was absolute, barring certain exceptions,

    including for a continuing wrong / breach / offence that may be accepted

    as a ground for seeking exemption in an action for contempt.

    24. The power of the constitutional Courts to punish for contempt

    is however an inherent power recognized by Articles 129 and 215 of the
    17
    AIR 1935 PC 85

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    Constitution, as distinguishable from a power derived from Statute.

    Referring to the judgments in The Aligarh Municipal Board And Ors. v.

    Ekka Tonga Mazdoor Union And Ors18, Jhareswar Prasad Paul & Anr v.

    Tarak Nath Ganguly & Ors19 and In Re: Vinay Chandra Mishra20 , the

    Court reiterated that no law framed by legislature can take away the

    jurisdiction for contempt conferred on the Courts. Having said so, they

    also refer to certain other judgments such as AK Misra v State of Uttar

    Pradesh21, Pallav Seth (Footnote) and Ashok Kumar Agarwal Vs. Neeraj

    Kumar wherein the Courts have held, that the power, though a

    constitutional exercise, must be exercised in consonance with the

    provisions of a validly enacted law.

    25. Set in the context of the above discussion, we now proceed to

    decide the present matter. Admittedly, the institution of the contempt

    petition is barred by limitation. We have carefully perused the records

    and do not find any circumstances set out therein that might persuade us

    to exempt the present case from the limitation under the Act. In fact, the

    Appellant has not even made any reference to limitation in her contempt

    18
    (1970) 3 SCC 98
    19
    (2002) 5 SCC 352
    20
    (1995) 2 SCC 584
    21
    (1998) 7 SCC 379

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    petition, leave along providing justification and seeking exemption from

    the same.

    26. Dr.Chelliah has taken us through the judgment of Murugesa

    Gounder22, particularly, the observations at paragraph 33, referring to

    legal maxims to the effect that it is the duty of a good judge to ensure that

    justice is done. In light of our understanding of Section 20 as above based

    on the judgements of the Apex Court, this decision is of no assistance to

    the Appellant. We thus concur with the learned Judge that the contempt

    petition was barred by limitation.

    27. In the present case, the respondent has filed an appeal as

    against the order passed in writ petition. There has been some discussion

    on whether the appellant had undertaken not to press the contempt

    petition and we do not find anything in the records to indicate so.

    However, it is unnecessary for us to say anything further in that regard as

    we have decided the bar of limitation against the appellant.

    28. Section 19 of the Act dealing with ‘Appeals’ states that an

    appeal shall lie as a matter of right in the exercise of jurisdiction ‘to

    punish for contempt’ and this has been interpreted by the Supreme Court

    in the case of Mindapore Peoples Coop. Bank Ltd and Others v Chunilal
    22
    Foot Note supra 2

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    Nanda and Others23 in the following terms:-

    “1. The position emerging from these decisions, in regard to
    appeals against orders in contempt proceedings may be
    summarized thus :

    I. An appeal under section 19 is maintainable only against an
    order or decision of the High Court passed in exercise of its
    jurisdiction to punish for contempt, that is, an order imposing
    punishment for contempt.

    II. Neither an order declining to initiate proceedings for
    contempt, nor an order initiating proceedings for contempt nor
    an order dropping the proceedings for contempt nor an order
    acquitting or exonerating the contemnor, is appealable
    under Section 19 of the CC Act. In special circumstances, they
    may be open to challenge under Article 136 of the Constitution.

    29. The position that emerges with clarity is that an appeal under

    Section 19 can be maintained only if the impugned order has imposed

    punishment for contempt. There is no other situation where an appeal

    may be maintained under Section 19 as against an order passed in

    contempt petition.

    30. Mr.Anand Gopalan, learned counsel has relied upon an order

    passed by us in the case of M.Devaraj & others Vs. Noor Mohammed,

    Superintending Engineer, Thiruvannamalai24. In that case too, we have

    referred to the judgment in Midnapore Peoples’ Coop. Bank Ltd25,

    confirming the order of the learned Single Judge.

    23
    (2006) 5 SCC 399
    24
    LPA No. 2 of 2020 dated 4.3.2026
    25
    Foot note supra 5

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    31. Incidentally, in that case, there were certain observations made

    on the rights of the parties, and we held that those observations were

    superfluous and would not influence the learned judge when dealing with

    the writ petition on merits.

    32. In light of the discussion as aforesaid, we dismiss this appeal as

    being not maintainable. No costs.

    (A.S.M.,J.) (S.M.,J.)

    -07-2026
    Index: Yes/No
    Speaking order
    Neutral Citation: Yes

    dp

    1. J.Radhakrishnan
    Chairman and Managing Director,
    TANGENDCO,
    New NO.144, Anna Salai
    N.P.K.R.R.Maligai
    Chennai-600002

    2. M.Ambiga
    Chief Engineer (Personnel)
    TANGENDCO
    New No.144, Anna Salai
    Chennai-600002

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    LPA No. 3 of 2026

    DR.ANITA SUMANTH J.

    AND
    SUNDER MOHAN J.

    dp

    LPA No. 3 of 2026
    AND
    CMP NO. 10754 OF 2026

    13.07.2026

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